SATYANARAYANA RAJU, J.

This is a revision petition filed by the State of Andhra against the decision of the Sales Tax Appellate Tribunal in T.A. No. 56-A of 1953.

The respondent is the son of one K. Janakiram Naidu, who was a railway contractor doing business under the name and style of K. Janakiram Naidu and Sons at Kodur. The father having died, the five sons of the said Janakiram Naidu, of whom the 3rd is the respondent herein, executed a deed of partnership on the 7th of July, 1943, in and by which they had mutually agreed to become partners subject to terms contained in the deed. The deed provides inter alia that the partnership shall be in force for a period of five years from 20th May, 1943, and on the expiry of the period, for such further time as the partners may mutually agree. The partnership was dissolved on the 17th of December, 1951, by a memorandum of agreement entered into at Madras between the respondent and his brothers. It recites that the brothers have been carrying on partnership business under the name and style of Messrs K. Janakiram Naidu and Sons, that disputes have arisen between them regarding the sharing of the assets and liabilities of the abov